WASHINGTON - Despite persistent fears of mad cow disease in Canadian beef, the Department of Agriculture has failed to properly track hundreds of Canadian cattle coming into the United States, the department's inspector general has concluded.

An audit, completed in March but only recently made public, said that some of the imported cattle did not have proper identification or health records despite federal regulations requiring them.

The audit did not say how many cattle were improperly brought into the U.S. and inspector general spokesman Paul Feeney said auditors are not sure of that number. The report said that a lack of records meant that "it cannot be determined" whether shipments other than those discovered "have bypassed inspection or whether this is a systemic problem."

About 1 million cattle were imported into the U.S. from Canada in the fiscal year ending in September 2006, the period covered by the audit.

The audit mainly faulted Agriculture's Animal Plant Health Inspection Service for failing to properly check records as the cattle crossed the Canadian border.

"APHIS does not adequately track live animal imports and, if problems are detected, does not collectively analyze import violations," the report said. "Additional controls are needed at northern ports-of-entry to obtain stronger assurance that all animal shipments are inspected."

Mad cow, or bovine spongiform encephalopathy, is a disease that attacks a cow's nervous system. Medical researchers also believe that humans who eat meat infected with BSE can contract a variant of Creutzfeldt-Jakob disease, which is fatal.

When mad cow was first discovered in Canada in 2003, the USDA cut off all Canadian cattle imports, as did many other countries.

But despite years of precautions, Canada continues to discover cases in which cows have BSE. In June, Canada discovered its 13th BSE case.

The U.S. also discovered a case of mad cow in late 2003. It was found in a Washington state dairy cow that had been imported from Canada. Two more U.S. cases of the disease have since been confirmed — one Texas-bred cow and one in Alabama whose origin is not known.

The American beef industry also suffered a financial setback after many countries banned U.S. beef.

The USDA began testing suspect cattle in 2004, and about 400,000 cattle a year were tested. But in 2006 top USDA officials argued that the risk of mad cow disease was minimal, and testing was scaled back to about 40,000 head a year. About 97 million head of cattle are in the U.S.

In 2005, the Agriculture Department began to allow imports of Canadian cattle, which are cheaper than U.S. cattle, in part because so many countries prohibited importing Canadian beef.

There were import restrictions, though. The USDA first allowed only Canadian cattle younger than 30 months old, since mad cow is believed to fully afflict only older cattle.

But in November the department also began to allow older cattle, arguing that no new mad cow cases have been discovered in the U.S. since 2006 and that safeguards were in place to minimize the risk.

Karen Eggert, an APHIS spokeswoman, said the audit covered a period in 2006, before older cattle were allowed into the U.S. She also said the agency has adhered strictly to a rule adopted in December 2004 that dictates strict conditions for the import of Canadian cattle.

Those conditions include health and identification procedures, sealed trucks, permanent markings on cattle and restrictions on their movement once in the U.S.

Eggert said that her agency disagrees with some of the audit's findings but that "other recommendations have provided us with sound ideas."

In one instance, the audit concluded, 211 cattle entered the U.S. without proper identification or health records.

In another, auditors found that 161 "animal shipments gained unauthorized entry into the United States during [fiscal years] 2005 and 2006." A typical cattle shipment contains about 60 animals.

The audit also found that 436 cattle and 9,000 hogs were sent to the U.S. for slaughter, but that their slaughter could not be verified.

Critics of the Agriculture Department's mad cow policies said the audit bolsters their call to ban imports. A cattle producers group, R-Calf USA, sued the agency over the rule that allows older cattle from Canada into the U.S. In a partial victory, a federal judge in South Dakota on July 3 ordered the agency to reconsider that rule.

"We know that Canada has an ongoing disease problem," Bullard said. "These rules that recently relaxed our import restrictions should be reversed until the agency can demonstrate that it has the capacity and the will to carry out its congressional mandate to protect consumers and the cattle producers against the introduction of disease."

Audit Report USDA’s Controls Over the Importation and Movement of Live Animals Report No. 50601-0012-Ch March 2008

Executive Summary

USDA’s Controls Over the Importation and Movement of Live Animals

Results in Brief This report presents the results of our audit to evaluate the effectiveness of the U.S. Department of Agriculture’s (USDA) controls over the importation and movement of live animals. Under the authority of the Animal Health Protection Act, USDA’s Animal and Plant Health Inspection Service (APHIS) regulates the importation of live animals. During fiscal year (FY) 2006, over 20 million animals were brought into the United States.1 Over 99 percent of these animals were imported from Canada and Mexico. Shipments of live animals are met at the border by officials from the Department of Homeland Security Customs and Border Protection (CBP). In accordance with a Memorandum of Agreement with APHIS, CBP refers live animal shipments to the APHIS port-of-entry veterinarian for inspection.2

APHIS port-of-entry veterinarians review import documentation3 and perform a visual inspection of the animals from outside the conveyance or by offloading the animals into pens and then inspecting them. If necessary,4 APHIS port-of-entry veterinarians secure the doors of the conveyance with official USDA seals.5 Different requirements exist for each species of imported animal, but most imported animals require a health certificate to enter the United States. A licensed veterinarian from the country of origin inspects the animals, then signs the health certificate certifying the health status of the animals and that U.S. import requirements are met. The certificate is then endorsed and sealed by a veterinary official from the country of origin. The most common certification is that the animal(s) to be imported were inspected and determined to be free of communicable disease.

APHIS works with the Food Safety and Inspection Service (FSIS) at designated slaughter establishments to ensure the proper handling of imported animals sent to slaughter. At each slaughter establishment, an FSIS veterinarian inspects the animals and verifies that the import documentation is complete and, if applicable, that the seals on the conveyance are present and unbroken. An FSIS official signs the import documents and returns a copy to

1 Source: APHIS’ Import Tracking System database.

2 Memorandum of Agreement signed by both Departments’ Secretaries on February 28, 2003.

3 Declaration for Importation; APHIS Form 17-29, Animals, Animal Semen, Animal Embryos, Birds, Poultry, or Hatching Eggs; and health certificates from the country of origin.

4 Veterinary Services Memorandum 591.15 Importation of Restricted Animals from Canada and Mexico for Immediate Slaughter, establishes procedures for the handling of untested (restricted) animals; 9 CFR Part 93, dated July 27, 2006, specifies import requirements by animal type, including pertinent testing requirements. For example, bovine entering the U.S. from Mexico do not require the use of seals when sent to a feedlot.

5 Certain shipments of live animals are required to have the conveyance doors secured with an official USDA seal to maintain the integrity over restricted movements; e.g., Canadian bovine or swine.

the APHIS port-of-entry, or area office, to confirm that the shipment was received.6 Our audit concluded that APHIS’ controls over live animal imports need to be strengthened to prevent, detect, and address the entry of live animals that do not meet import requirements. While APHIS relies on country of origin health certificates certifying the animal’s health condition, age, and/or other import requirements, it does not have adequate processes in place to follow up and determine whether individual problems detected represent a larger systemic noncompliance that needs to be addressed by agency inspection personnel or the country of origin. Import problems that are detected are generally handled locally and are not assessed from a program management perspective.

APHIS does not have effective systems or controls for approving and/or tracking live animals into the United States. We found animals entered the country without APHIS inspection. An internal APHIS review of ports-of-entry in September 2004, also disclosed that live animals bypassed inspection.7 APHIS relies on a manual process to account for and track the movement of animals from CBP to APHIS inspection at the border and to their final destination (e.g., feedlots, slaughter establishments). APHIS does not always reconcile or follow up on discrepancies in the number of animals arriving at their final destinations as compared to those approved for entry into the United States. Therefore, APHIS cannot always demonstrate that all restricted8 animals are slaughtered. Also, we found inadequate accountability over the inventory and issuance of official USDA seals used to secure the movement of restricted animals after inspection at the port-of-entry.

Homeland Security Presidential Directive 9 establishes a national policy to defend the agriculture and food system against terrorist attacks, major disasters, and other emergencies, which includes enhancing screening procedures for domestic and imported products. Because we believe these issues represent potential homeland security weaknesses, on May 1, 2007, we issued a Management Alert to both APHIS and FSIS during our fieldwork and made recommendations for immediate corrective action.

APHIS recognizes the need to develop automated controls over its live animal import process. It is developing the Veterinary Services Process Streamlining (VSPS) system, which is expected to replace existing manual, paper-oriented processes. VSPS is expected to provide a more comprehensive

6 Documents for animals imported for immediate slaughter are returned to the APHIS port-of-entry; documents for animal movements from approved feedlots to slaughter establishments are returned to the applicable APHIS area office.

7 APHIS conducted an internal Safeguarding Review of operations at 23 ports-of-entry in September 2004.

8 The term “restricted” refers to specific requirements imposed by APHIS to limit the movements of certain animals. For example, the movement of feeder bovine from Canada was restricted to one feedlot where the feeder bovine must remain until transported under seal to a slaughter establishment.

USDA/OIG-A/50601-0012-Ch Page iii

tool for animal tracking and disease analysis which, in turn, would allow APHIS to respond more quickly to any threats to animal health in the United States. However, the live animal import module of VSPS has already been delayed for more than 2 years due to other agency priorities, and it is not anticipated to be completed before September 2008. Until this system is fully implemented, interim actions need to be taken to strengthen controls and to track the movement of live animals into the United States.

In response to our Management Alert, APHIS officials stated that they are committed to ensuring all of APHIS’ regulatory controls are sufficient. They formed a working group of experts from APHIS and FSIS to examine import protocols, pre-import clearance requirements, procedures at ports-of-entry, and import controls at feedlots and slaughter facilities. On November 27, 2007, APHIS officials provided OIG with their report on the conclusions presented by the working group. Overall, the working group determined that most of the concerns OIG identified could be corrected

don't these dummies know by now that the USA does not have any mad cow disease and or any human cjd ramifications from a mad cow, cause the USDA says so... NOT

there has been a decade old, systematic cover-up of corporate homicide just because of trade, futures and commodities. the elderly demented, your grandma and grandpa, mom and dad, sisters and brothers, are all expendable, due to the fact the American joe-cue-public is just to damn lazy to care. the elderly and demented are expendable. but mark my word here and now, it's here, and has been, call it what you like.....

10 people killed by new CJD-like disease

Public release date: 9-Jul-2008

Since Gambetti's team wrote a paper describing an initial 11 cases referred to his centre between 2002 and 2006 (Annals of Neurology, vol 63, p 697), another five have come to light. "So it is possible that it could be just the tip of the iceberg," Gambetti says.

why is a cjd questionnaire not listed on the cjd foundation 'forms' site with the rest of their forms ???

i thought they had one now going out to all families of victims of a human TSE???

this is very important that a _written_ cjd questionnaire, asking extensive questions pertaining to any potential route and source of the TSE agent be submitted to every family of a victim of a human TSE. this is key to finding cause. so why is this still so difficult? are the families of CJD victims getting these written cjd questionnaires??? i hope so....

2008 The statistical incidence of CJD cases in the United States has been revised to reflect that there is

_one case per 9000 in adults age 55 and older_.

Eighty-five percent of the cases are sporadic, meaning there is no known cause at present.

we know how clusters are handled in NJ too. as long as the infamous UKBSEnvCJD only theory is in play, the CDC et al will play it out to the T. no other science will exist, and it does not matter that the last two mad cows in the USA were atypical BSE. as old stan said, nothing else matters, just the beef crossing the borders. just because science is now pointing to not only BSE to nvCJD, but atypical BSE looking like some sub types of sporadic CJD, atypical scrapie looking also like some sub types of sporadic CJD. CWD to humans as ? come on folks, how long can this same sad masquerade keep on playing out$$$

An Evaluation of a Suspected Cluster of Creutzfeldt-Jakob Disease (CJD) in New Jersey May 2004 Division of Epidemiology, Environmental and Occupational Health

snip...

If consumption of BSE contaminated beef at the GSRT between 1988 and 1992 caused sporadic CJD, the data should show increases in the numbers of case-patients by now, assuming the same lag (incubation) period as vCJD.

-- the scientists who say it exists; the heartbroken family members who doubt it. Early, deep in his grief, he would sign his e-mail messages to scientists, ''I am the madson of a deadmom who died of madcow.'' Singeltary turned out to be helpful for Skarbek. He pointed her to a paper that was published in 2002 in the journal of the European Molecular Biology Organization by John Collinge, the premier prion researcher in England. Collinge argued that experiments conducted in mice suggest that infections with mad cow can sometimes look like sporadic C.J.D. Collinge accepted the implications: he recommended that ''serious consideration should be given'' to the idea that some of the more recent sporadic C.J.D. cases in Europe were in fact related to mad cow disease.

i hate to inform them, but sporadic CJD has increased. sporadic CJD in the USA went from 28 cases _documented_ in 1997, to 170 cases of sporadic CJD _documented_ in 2007. i'm not a math wiz, but looks like an increase to me. ...

6 Includes 55 cases with type determination pending in which the diagnosis of vCJD has been excluded.

hmmm, they can exclude vCJD, but yet include them as a prion disease, but yet not know what the hell it is, and at the same time, keep telling everyone i.e. media, that ;

>>>Further tests will be conducted to determine the cause of the Cape patient's illness, but state disease trackers said there is nothing to suggest that the patient's case is associated with mad cow disease. Instead, like virtually all cases in the United States, it is almost certainly not linked to any obvious external cause.<<<

stupid is, as stupid does, and joe-q-public continues to believe this garbage. ...TSS He added that because the CDC only provide information on diseases, they have no plans to make a separate press release on the issue including the result of the investigation. and that is the way they plan to keep it, all spontaneous, sporadic, no route, no source $$$

DEEP THROAT TO TSS 2000-2001 (take these old snips of emails with how ever many grains of salt you wish. ...tss)

The most frightening thing I have read all day is the report of Gambetti's finding of a new strain of sporadic cjd in young people...

Dear God, what in the name of all that is holy is that!!! If the US has different strains of scrapie.....why????than the UK...

then would the same mechanisms that make different strains of scrapie here make different strains of BSE...if the patterns are different in sheep and mice for scrapie.....could not the BSE be different in the cattle, in the mink, in the humans.......I really think the slides or tissues and everything from these young people with the new strain of sporadic cjd should be put up to be analyzed by many, many experts in cjd........bse.....scrapie Scrape the damn slide and put it into mice.....wait.....chop up the mouse brain and and spinal cord........put into some more mice.....dammit amplify the thing and start the damned research.....This is NOT rocket science...we need to use what we know and get off our butts and move....the whining about how long everything takes.....well it takes a whole lot longer if you whine for a year and then start the research!!!

Not sure where I read this but it was a recent press release or something like that: I thought I would fall out of my chair when I read about how there was no worry about infectivity from a histopath slide or tissues because they are preserved in formic acid, or formalin or formaldehyde.....for God's sake........ Ask any pathologist in the UK what the brain tissues in the formalin looks like after a year.......it is a big fat sponge...the agent continues to eat the brain ......you can't make slides anymore because the agent has never stopped........and the old slides that are stained with Hemolysin and Eosin......they get holier and holier and degenerate and continue...what you looked at 6 months ago is not there........Gambetti better be photographing every damned thing he is looking at.....

Okay, you need to know. You don't need to pass it on as nothing will come of it and there is not a damned thing anyone can do about it. Don't even hint at it as it will be denied and laughed at.......... USDA is gonna do as little as possible until there is actually a human case in the USA of the nvcjd........if you want to move this thing along and shake the earth....then we gotta get the victims families to make sure whoever is doing the autopsy is credible, trustworthy, and a saint with the courage of Joan of Arc........I am not kidding!!!! so, unless we get a human death from EXACTLY the same form with EXACTLY the same histopath lesions as seen in the UK nvcjd........forget any action........it is ALL gonna be sporadic!!!

And, if there is a case.......there is gonna be every effort to link it to international travel, international food, etc. etc. etc. etc. etc. They will go so far as to find out if a sex partner had ever traveled to the UK/europe, etc. etc. .... It is gonna be a long, lonely, dangerous twisted journey to the truth. They have all the cards, all the money, and are willing to threaten and carry out those threats....and this may be their biggest downfall...

Thanks as always for your help. (Recently had a very startling revelation from a rather senior person in government here..........knocked me out of my chair........you must keep pushing. If I was a power person....I would be demanding that there be a least a million bovine tested as soon as possible and agressively seeking this disease. The big players are coming out of the woodwork as there is money to be made!!! In short: "FIRE AT WILL"!!! for the very dumb....who's "will"! "Will be the burden to bare if there is any coverup!"

again it was said years ago and it should be taken seriously....BSE will NEVER be found in the US! As for the BSE conference call...I think you did a great service to freedom of information and making some people feign integrity...I find it scary to see that most of the "experts" are employed by the federal government or are supported on the "teat" of federal funds. A scary picture! I hope there is a confidential panel organized by the new government to really investigate this thing.

You need to watch your back........but keep picking at them.......like a buzzard to the bone...you just may get to the truth!!! (You probably have more support than you know. Too many people are afraid to show you or let anyone else know. I have heard a few things myself... you ask the questions that everyone else is too afraid to ask.)

Monday, May 5, 2008

STATEMENT OF DR. RICHARD RAYMOND USDA UNDERSECRETARY FOR FOOD SAFETY Regarding the Safety of the U.S. Food Supply

May 4, 2008

“Good evening. I am Dr. Richard Raymond, Under Secretary for Food Safety at the U.S. Department of Agriculture. I appreciate the opportunity to discuss with you the safety of the U.S. beef supply. I want to be sure that you are aware that I will be discussing food safety issues only, and I am not here this evening to discuss negotiations. “The U.S. Government believes the current agreement well addresses the health and food safety concerns of Korean consumers. It provides for Korea's sovereign right to conduct an audit of our facilities and to work with USDA inspection authorities if any food safety concerns are identified. When the OIE gave the United States "controlled risk" status a year ago, it was after the world's BSE experts reviewed the preventative and food safety measures in the United States. “Since the requirements to export to Korea are consistent with science, U.S. requirements as well as those of the OIE require that if any food safety concern is found, it would be fully investigated and immediately corrected by USDA. “I want to assure all consumers – both domestic and abroad – that the U.S. beef supply is among the safest in the world. To help ensure its safety, USDA takes a number of steps to prevent foodborne illness. USDA’s Food Safety and Inspection Service (FSIS) employs over 9,000 personnel, including 7,800 full-time in-plant and other front-line personnel protecting the public health in approximately 6,200 federally inspected establishments nationwide. FSIS personnel must be continuously present for slaughter operations and observe the animal both in motion and at rest before slaughter, and every carcass after slaughter. FSIS also must be present in each processing establishment every shift every day. Under the FSIS verification sampling program, FSIS samples meat, poultry, and processed egg products and analyzes them for the presence of microbial pathogens. To protect against bovine spongiform encephalopathy (BSE), the U.S. government also has an interlocking system of safeguards. Safeguards Against BSE “I would like to take this opportunity to give you a brief summary of the safeguards against BSE that the United States has in place to protect our food supply. “Since the discovery of the first case of BSE in Great Britain in 1986, we have learned a tremendous amount about this disease. That knowledge has greatly informed USDA’s regulatory systems and response efforts. It has also given us the opportunity to examine our own cattle herd, which is why we know that the risk of BSE in the United States is extremely low. “The U.S. government’s interlocking system of controls to protect the food supply from BSE includes a ban on non-ambulatory disabled cattle since January 2004. On July 12, 2007, FSIS announced a permanent prohibition on the non-ambulatory disabled or “downer” cattle from the food supply, with the exception of otherwise normal, healthy animals that become non-ambulatory because of an acute injury after passing ante-mortem inspection.

2

“We have learned that the single most important thing we can do to protect human health regarding BSE is the removal from the food supply of specified risk materials (SRMs) – those tissues that, according to scientific evidence, could be infective in a cow with BSE. USDA requires that all SRMs are removed from carcasses so that they do not enter the food supply. Slaughter facilities cannot operate their slaughter operations without the continuous presence of USDA inspection personnel to ensure safe and wholesome product, including the removal, segregation and disposal of SRMs. According to the 2005 Harvard Risk Assessment, SRM removal alone reduces the potential exposure to consumers of BSE by 99 percent. USDA inspectors are stationed at key points along the production line where they are able to directly observe certain SRM removal activities. Other off-line inspection personnel verify additional plant SRM removal, segregation and disposal. Moreover, FDA bans SRMs in FDA-regulated human foods and cosmetics. “An additional significant step we have taken to prevent the spread of BSE and bring about its eradication in the animal population is the ruminant feed ban. In 1997, the FDA implemented a mandatory feed ban that prohibits feeding most mammalian protein to ruminants, including cattle. This rule was strengthened just recently in a final rule published April 25, 2008. The feed ban is a vital measure to prevent the transmission of BSE to cattle. While the 1997 rule provides a strong primary line of defense against BSE, as evidenced by the extremely low prevalence of BSE in the U.S., the additional measures taken in this final rule, which goes into effect 12 months from the date of publication, will further reinforce the existing rule by removing certain cattle derived materials from all animal feed. This action will minimize any residual BSE risks not eliminated by the 1997 rule, if cross contamination of ruminant feed with non ruminant feed, or diversion of non ruminant feeds to ruminants, were to occur. In fact, this feed ban goes beyond what is required by OIE, and that is significant. “Another step is BSE testing, which is best used as a surveillance tool. By testing high-risk animals, including those that show possible clinical signs of the disease, we can document the effectiveness of our security measures. “USDA’s Animal and Plant Health Inspection Service (APHIS) has conducted targeted BSE surveillance testing since 1990, including an enhanced surveillance effort that was initiated after a cow tested positive for the disease in December 2003. The goal of the enhanced effort, which began in June 2004, was to test as many animals in the targeted population of dead, down, or disabled cattle as possible over a 24-month period. Out of over 759,000 animals tested, this intensive effort detected only two additional animals with the disease. Both of those animals were born prior to initiation of the FDA feed ban and neither entered the food supply. This testing confirms an extremely low prevalence of the disease in the United States and the efficacy of the feed banning preventing transmission of BSE to the American herd. “The enhanced surveillance program provided sufficient data to allow USDA to more accurately estimate the prevalence or level of BSE within the U.S. cattle population. Based on this analysis, we can definitively say that the incidence of BSE in the United States is extremely low. APHIS continues to conduct an ongoing BSE surveillance program targeted to high-risk animals that samples approximately 40,000 high-risk animals annually. This level of surveillance significantly exceeds the guidelines set forth by the World Animal Health Organization, which has affirmed that U.S. regulatory controls against the disease are effective.

3

“It is because of the strong system that the United States has put in place, and which we continue to work to strengthen, that we can be confident of the safety of our beef supply in regard to BSE and that the spread of BSE has been prevented in this nation. Hallmark/Westland Meat Packing Co. “I also want to discuss with you the undercover video by the Humane Society that was released on January 30. As soon as the video was released, USDA Secretary Schafer called for an investigation into the matter. USDA’s Office of the Inspector General (OIG) is leading that investigation, with support from FSIS and the Agricultural Marketing Service (AMS). This investigation is still ongoing, and in the meantime, FSIS has implemented a series of interim actions to verify and thoroughly analyze humane handling activities in federally inspected establishments. “When we learned of the problems at Hallmark/Westland on January 30, FSIS took immediate steps to determine if the allegations made public by the Humane Society of the United States (HSUS) were accurate. I also want to stress to you that the animals in the video are in no way indicative of animals that would ever pass ante-mortem inspection. “Evidence from the ongoing investigation demonstrates that, over the past two years, this plant did not always notify the FSIS public health veterinarian (PHV) when cattle became non-ambulatory after passing ante-mortem (prior to slaughter) inspection, as is required by FSIS regulations. This failure by Hallmark/Westland led to the company’s February 17, 2008, voluntary recall of 143 million pounds of fresh and frozen beef products produced at the establishment since February 1, 2006. Because of the previously explained interlocking safeguards against BSE exposure, it is extremely unlikely that these meat products pose a risk to human health. The recall action was deemed necessary because the establishment did not comply with FSIS regulations. This recall was not about food safety. “It is important to note that certain cattle, while ambulatory when they pass ante-mortem inspection, may later become non-ambulatory from an acute injury or another circumstance. If such a situation occurs, FSIS regulations require the PHV to inspect the animal again and determine that the animal did indeed suffer from an acute injury before the animal is permitted to go to slaughter. Otherwise, the animal is condemned, does not go to slaughter, and therefore, does not enter the food chain. It is also significant to understand that this plant had five full-time USDA inspectors who were doing their jobs to protect public health. Over the last three years, these inspectors condemned five percent of the cattle that were presented for slaughter. Most of the condemned were as a result of carcass and/or organ inspection post slaughter. “Last year, humane handling violations resulted in FSIS issuing notices of suspension of inspection, which effectively stop operations at a facility, to 12 of nearly 800 livestock slaughter plants. In 2007, FSIS issued 685 non-compliance records for humane handling issues out of more than 168,000 humane handling verification procedures – demonstrating that there is a very low level of less than egregious activity in plants. In general, these violations are minor and do not affect the safety and wholesomeness of our food supply. USDA believes that operating our inspection system in a transparent manner keeps our consumers informed and helps us strengthen an already strong food safety system.

4

Further Actions“The investigation led by OIG with support from FSIS and AMS is ongoing. However, we are not waiting for the completion of the investigation to act. “USDA has already taken a number of steps to strengthen our inspection system. FSIS has increased the amount of time allocated per shift by inspection program personnel to verify humane handling activities and to verify that animals are handled humanely in ante-mortem areas. FSIS is focusing surveillance and inspection activities at establishments where older or potentially distressed animals are slaughtered, such as facilities that handle dairy or veal cattle. At these facilities, the time spent performing humane handling verification activities will be doubled. At facilities with contracts for for Federal nutrition assistance programs, humane handling verification time is being doubled, regardless of the type or class of the animal slaughtered. “FSIS is also conducting surveillance activities to observe the handling of animals outside the approved hours of operation from vantage points within and adjacent to the official premises. FSIS has been and will continue to conduct humane handling audits in additional plants across the U.S. Additional Information “One last point that I would like to address is regarding a human health issue. I am certain that many of you are aware that an investigation was being conducted to determine the cause of death from a young patient in Virginia who was recently reported in the in the media to have died of variant Creutzfeldt-Jacob disease (vCJD). The epidemiologic characteristics of the illness and preliminary results of the neuropathologic testing of brain tissue obtained at autopsy indicate that the patient did not die of vCJD. The U.S. Centers for Disease Control and Prevention has just provided us with that information, and I felt it was important to share that with you today. An official release once all testing is completed and confirmed is expected soon, but the CDC has allowed me to offer you this preliminary information today. Conclusion “Again – I want to stress to all consumers – both domestic and abroad – that U.S. beef is safe. USDA takes a number of steps to prevent foodborne illness. The U.S. government’s interlocking system of controls to protect the food supply from BSE is effective and provide a level of security recognized as significant worldwide.” ### NOTE: Access news releases and other information at the FSIS Web site at http://www.fsis.usda.gov/.

a few facts Dr. Richard Raymond seems to might have overlooked. i thought i would kindly bring them to your attention. ...tss

Wednesday, April 30, 2008

Health group urges overhaul of US food safety system Calling the US food safety system antiquated and disjointed, a public health advocacy group today urged a major overhaul to make the system stronger, more coherent, and better attuned to today's major threats.

Progress Report from the National Prion Disease Pathology Surveillance Center April 3, 2008

Progress Report from the National Prion Disease Pathology Surveillance Center

An Update from Stephen M. Sergay, MB, BCh & Pierluigi Gambetti, MD

April 3, 2008

Dear Member:

Once again we are writing to thank you for your continued support in enhancing surveillance of prion diseases in the United States and to bring you up to date on the National Prion Disease Pathology Surveillance Center (NPDPSC).

In large part because of your support, the number of cases examined by biopsy, autopsy and 14-3-3 protein determination has increased significantly over the years (see Tables 1 and 2). We are now able to establish a definitive diagnosis of prion disease in an estimated 60-70% of the cases in the United States, a percentage which exceeds that in even some major surveillance centers. In addition, we receive from you cerebrospinal fluid (CSF) for 14-3-3 determination, a surrogate protein which is helpful in the diagnosis of prion disease, probably in most if not all cases of suspected Creutzfeldt-Jakob disease (CJD). We are making constant efforts to reach our goal of at least 80% definitively diagnosed cases.

The major obstacle to our further increasing the autopsy rate remains the inadequate reporting of suspected cases of CJD to the NPDPSC or to the State Health Department, which in turn would notify us. Since you are the one likely to request the 14-3-3 test on these cases, please include in your request the information needed to contact you, which we will do if the test proves positive. If your institution uses a referral laboratory to send us the CSF, please provide your name, phone, and fax numbers to the lab, which will in turn submit it to us along with the sample. If this information is missing in the request accompanying the CSF sample (as it happens in about 30% of the cases), we will be unable to contact the caregiving physician. Having your contact information would also allow us to send results directly to you, thus reducing turnaround times. ...

snip...

Prion surveillance in cattle has been reduced by 90% (from about 470,000 to 40,000 in the U.S. in 2007 out of about 35 million cattle slaughtered). Termination of human prion surveillance would therefore remove the second line of surveillance, thereby eliminating prion surveillance in the U.S. entirely. This development would be extremely worrisome in view of recent reports that precautions to limit the spread of the prion infectious agent may not have been followed in some slaughter houses in the U.S. Cattle affected with bovine spongiform encephalopathy (BSE) continue to be discovered in Canada, which has more rigorous BSE surveillance than the U.S. At the same time, Canada imposes few limitations in the trade of potentially prion-infectious cattle with the U.S.

snip...

Atypical forms of BSE have emerged which, although rare, appear to be more virulent than the classical BSE that causes vCJD.

[In submitting these data, Terry S. Singeltary Sr. draws attention to the steady increase in the "type unknown" category, which, according to their definition, comprises cases in which vCJD could be excluded. The total of 26 cases for the current year (2007) is disturbing, possibly symptomatic of the circulation of novel agents. Characterization of these agents should be given a high priority. - Mod.CP]

Answering critics like Terry Singeltary, who feels that the U.S. under- counts CJD, Schonberger conceded that the current surveillance system has errors but stated that most of the errors will be confined to the older population.

What is CJD? Creutzfeldt-Jakob Disease (CJD) is a rare, fatal brain disorder. The statistical incidence of CJD cases in the United States has been revised to reflect that there is one case per 9000 in adults age 55 and older. Eighty-five percent of the cases are sporadic, meaning there is no known cause at present.

THESE cases that have come about recently in the very young are most disturbing.

a 22 year old last week died, she is suspect nvCJD. never left US. PORTSMOUTH, Va. -- A 22-year-old Portsmouth woman is close to dying, and family says doctors believe the human equivalent of Mad Cow Disease could be the reason.

another young female suspect nvCJD that is 26 years old in Alabama, She is in the final stages of CJD. She is at home in a hospital bed...very skinny...and at times in the past month has had some eating and swallowing issues. Sometimes she rallies and starts eating again. She stopped walking at Christmas. they do not expect her to live much longer than May, since that would be 14 months since her first major symptom of CJD (personal communication).

AND now, a 3rd young female, 23 years old. hmmm, i am pondering about just how long all those downers were in the school lunch program, and IS the incubation period catching up now ???

THE only fool is one who fools himself, and GW and his administration and their junk science will fool humans for just so long, then the incubation will catch up. none of this was about science, it was all about commodities and futures and the exporting of beef. nothing else mattered, literally, just ask old stanley prusiner the nobel prize winner for the PRION, what did old stan say ;

In this context, a word is in order about the US testing program. After the discovery of the first (imported) cow in 2003, the magnitude of testing was much increased, reaching a level of >400,000 tests in 2005 (Figure 4). Neither of the 2 more recently indigenously infected older animals with nonspecific clinical features would have been detected without such testing, and neither would have been identified as atypical without confirmatory Western blots. Despite these facts, surveillance has now been decimated to 40,000 annual tests (USDA news release no. 0255.06, July 20, 2006) and invites the accusation that the United States will never know the true status of its involvement with BSE.

In short, a great deal of further work will need to be done before the phenotypic features and prevalence of atypical BSE are understood. More than a single strain may have been present from the beginning of the epidemic, but this possibility has been overlooked by virtue of the absence of widespread Western blot confirmatory testing of positive screening test results; or these new phenotypes may be found, at least in part, to result from infections at an older age by a typical BSE agent, rather than neonatal infections with new "strains" of BSE. Neither alternative has yet been investigated.

The U.S. Department of Agriculture was quick to assure the public earlier this week that the third case of mad cow disease did not pose a risk to them, but what federal officials have not acknowledged is that this latest case indicates the deadly disease has been circulating in U.S. herds for at least a decade.

The second case, which was detected last year in a Texas cow and which USDA officials were reluctant to verify, was approximately 12 years old.

These two cases (the latest was detected in an Alabama cow) present a picture of the disease having been here for 10 years or so, since it is thought that cows usually contract the disease from contaminated feed they consume as calves. The concern is that humans can contract a fatal, incurable, brain-wasting illness from consuming beef products contaminated with the mad cow pathogen.

"The fact the Texas cow showed up fairly clearly implied the existence of other undetected cases," Dr. Paul Brown, former medical director of the National Institutes of Health's Laboratory for Central Nervous System Studies and an expert on mad cow-like diseases, told United Press International. "The question was, 'How many?' and we still can't answer that."

Brown, who is preparing a scientific paper based on the latest two mad cow cases to estimate the maximum number of infected cows that occurred in the United States, said he has "absolutely no confidence in USDA tests before one year ago" because of the agency's reluctance to retest the Texas cow that initially tested positive.

USDA officials finally retested the cow and confirmed it was infected seven months later, but only at the insistence of the agency's inspector general.

"Everything they did on the Texas cow makes everything USDA did before 2005 suspect," Brown said. ...snip...end

"Actually, Terry, I have been critical of the USDA handling of the mad cow issue for some years, and with Linda Detwiler and others sent lengthy detailed critiques and recommendations to both the USDA and the Canadian Food Agency."

Our prior report identified a number of inherent problems in identifying and testing high-risk cattle. We reported that the challenges in identifying the universe of high-risk cattle, as well as the need to design procedures to obtain an appropriate representation of samples, was critical to the success of the BSE surveillance program. The surveillance program was designed to target nonambulatory cattle, cattle showing signs of CNS disease (including cattle testing negative for rabies), cattle showing signs not inconsistent with BSE, and dead cattle. Although APHIS designed procedures to ensure FSIS condemned cattle were sampled and made a concerted effort for outreach to obtain targeted samples, industry practices not considered in the design of the surveillance program reduced assurance that targeted animals were tested for BSE.

USDA/OIG-A/50601-10-KC Page 27

observe these animals ante mortem when possible to assure the animals from the target population are ultimately sampled and the clinical signs evaluated.

I have learned about what you and your family have been through a internet. Being the father of a small family, I can only imagine the sense of loss that you and your family still must feel regarding your mother.

FDA has determined that each animal could have consumed, at most and in total, five-and-one-half grams - approximately a quarter ounce — of prohibited material. These animals weigh approximately 600 pounds.

On February 12, 17, 21, and 22, 2006, a U.S. Food & Drug Administration (FDA) investigator inspected your rendering plant, located at 509 Fortson Street, Shreveport, Louisiana. The inspection revealed significant deviations from the requirements set forth in Title 21, Code of Federal Regulations, Part 589.2000 [21 CFR 589.2000], Animal Proteins Prohibited in Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE). You failed to follow the requirements of this regulation; products being manufactured and distributed by your facility are misbranded within the meaning of Section 403(a)(1) [21 USC 343(a)(1)] of the Federal Food, Drug, and Cosmetic Act (the Act).

Our investigation found you failed to provide measures, including sufficient written procedures, to prevent commingling or cross-contamination and to maintain sufficient written procedures [21 CFR 589.2000(e)] because:

You failed to use clean-out procedures or other means adequate to prevent carryover of protein derived from mammalian tissues into animal protein or feeds which may be used for ruminants. For example, your facility uses the same equipment to process mammalian and poultry tissues. However, you use only hot water to clean the cookers between processing tissues from each species. You do not clean the auger, hammer mill, grinder, and spouts after processing mammalian tissues.

You failed to maintain written procedures specifying the clean-out procedures or other means to prevent carryover of protein derived from mammalian tissues into feeds which may be used for ruminants.

As a result . the poultry meal you manufacture may contain protein derived from mammalian tissues prohibited in ruminant feed. Pursuant to 21 CFR 589.2000(e)(1)(i), any products containing or may contain protein derived from mammalian tissues must be labeled, “Do not feed to cattle or other ruminants.” Since you failed to label a product which may contain protein derived from mammalian tissues with the required cautionary statement. the poultry meal is misbranded under Section 403(a)(1) [21 USC 343(a)(1)] of the Act.

This letter is not intended as an all-inclusive list of violations at your facility. As a manufacturer of materials intended for animal feed use, you are responsible for ensuring your overall operation and the products you manufacture and distribute are in compliance with the law. You should take prompt action to correct these violations, and you should establish a system whereby violations do not recur. Failure to promptly correct these violations may result in regulatory action, such as seizure and/or injunction, without further notice.

You should notify this office in writing within 15 working days of receiving this letter, outlining the specific steps you have taken to bring your firm into compliance with the law. Your response should include an explanation of each step taken to correct the violations and prevent their recurrence. If corrective action cannot be completed within 15 working days, state the reason for the delay and the date by which the corrections will be completed. Include copies of any available documentation demonstrating corrections have been made.

Corinne Ida Lasmézas, Emmanuel Comoy, Stephen Hawkins, Christian Herzog, Franck Mouthon, Timm Konold, Frédéric Auvré, Evelyne Correia, Nathalie Lescoutra-Etchegaray, Nicole Salès, Gerald Wells, Paul Brown, Jean-Philippe Deslys Summary The uncertain extent of human exposure to bovine spongiform encephalopathy (BSE)–which can lead to variant Creutzfeldt-Jakob disease (vCJD)–is compounded by incomplete knowledge about the efficiency of oral infection and the magnitude of any bovine-to-human biological barrier to transmission. We therefore investigated oral transmission of BSE to non-human primates. We gave two macaques a 5 g oral dose of brain homogenate from a BSE-infected cow. One macaque developed vCJD-like neurological disease 60 months after exposure, whereas the other remained free of disease at 76 months. On the basis of these findings and data from other studies, we made a preliminary estimate of the food exposure risk for man, which provides additional assurance that existing public health measures can prevent transmission of BSE to man.

To minimise the risk of farmers’ claims for compensation from feed compounders.

To minimise the potential damage to compound feed markets through adverse publicity.

To maximise freedom of action for feed compounders, notably by maintaining the availability of meat and bone meal as a raw material in animal feeds, and ensuring time is available to make any changes which may be required.

snip…

THE FUTURE

4……….

MAFF remains under pressure in Brussels and is not skilled at handling potentially explosive issues.

5. Tests _may_ show that ruminant feeds have been sold which contain illegal traces of ruminant protein. More likely, a few positive test results will turn up but proof that a particular feed mill knowingly supplied it to a particular farm will be difficult if not impossible.

6. The threat remains real and it will be some years before feed compounders are free of it. The longer we can avoid any direct linkage between feed milling _practices_ and actual BSE cases, the more likely it is that serious damage can be avoided. …

Food-animal production in the United States has changed markedly in the past century, and these changes have paralleled major changes in animal feed formulations. While this industrialized system of food-animal production may result in increased production efficiencies, some of the changes in animal feeding practices may result in unintended adverse health consequences for consumers of animal-based food products. Currently, the use of animal feed ingredients, including rendered animal products, animal waste, antibiotics, metals, and fats, could result in higher levels of bacteria, antibioticresistant bacteria, prions, arsenic, and dioxinlike compounds in animals and resulting animal-based food products intended for human consumption. Subsequent human health effects among consumers could include increases in bacterial infections (antibioticresistant and nonresistant) and increases in the risk of developing chronic (often fatal) diseases such as vCJD. Nevertheless, in spite of the wide range of potential human health impacts that could result from animal feeding practices, there are little data collected at the federal or state level concerning the amounts of specific ingredients that are intentionally included in U.S. animal feed. In addition, almost no biological or chemical testing is conducted on complete U.S. animal feeds; insufficient testing is performed on retail meat products; and human health effects data are not appropriately linked to this information. These surveillance inadequacies make it difficult to conduct rigorous epidemiologic studies and risk assessments that could identify the extent to which specific human health risks are ultimately associated with animal feeding practices. For example, as noted above, there are insufficient data to determine whether other human foodborne bacterial illnesses besides those caused by S. enterica serotype Agona are associated with animal feeding practices. Likewise, there are insufficient data to determine the percentage of antibiotic-resistant human bacterial infections that are attributed to the nontherapeutic use of antibiotics in animal feed. Moreover, little research has been conducted to determine whether the use of organoarsenicals in animal feed, which can lead to elevated levels of arsenic in meat products (Lasky et al. 2004), contributes to increases in cancer risk. In order to address these research gaps, the following principal actions are necessary within the United States: a) implementation of a nationwide reporting system of the specific amounts and types of feed ingredients of concern to public health that are incorporated into animal feed, including antibiotics, arsenicals, rendered animal products, fats, and animal waste; b) funding and development of robust surveillance systems that monitor biological, chemical, and other etiologic agents throughout the animal-based food-production chain “from farm to fork” to human health outcomes; and c) increased communication and collaboration among feed professionals, food-animal producers, and veterinary and public health officials.

Diagnosis of transmissible spongiform encephalopathy (TSE) disease in humans and ruminants relies on the detection in post-mortem brain tissue of the protease-resistant form of the host glycoprotein PrP. The presence of this abnormal isoform (PrPSc) in tissues is taken as indicative of the presence of TSE infectivity. Here we demonstrate conclusively that high titers of TSE infectivity can be present in brain tissue of animals that show clinical and vacuolar signs of TSE disease but contain low or undetectable levels of PrPSc. This work questions the correlation between PrPSc level and the titer of infectivity and shows that tissues containing little or no proteinase K-resistant PrP can be infectious and harbor high titers of TSE infectivity. Reliance on protease-resistant PrPSc as a sole measure of infectivity may therefore in some instances significantly underestimate biological properties of diagnostic samples, thereby undermining efforts to contain and eradicate TSEs.

————————————————————

Received for publication, May 25, 2007 , and in revised form, September 24, 2007.

* This work was supported by United Kingdom Department for Environment, Food, and Rural Affairs Grant SE1437. The costs of publication of this article were defrayed in part by the payment of page charges. This article must therefore be hereby marked “advertisement” in accordance with 18 U.S.C. Section 1734 solely to indicate this fact.

The on-line version of this article (available at http://www.jbc.org/) contains supplemental Figs. S1–S3 and Table S1.

USDA CERTIFIED SCHOOL LUNCH PROGRAM FROM DEAD STOCK DOWNER CATTLE i.e. the most high risk cattle for BSE/TSE

(IF you think that the largest recall in history was done just because a few cows were abused, and that this issue was not a food safety issue, well i have got news for you)

who's gonna be following these children over the next decade or so to see if they contract CJD ? the USDA? FSIS? FDA? CDC? NIH? we must not forget, these innocent children were exposed to the most high risk 'banned' animals for BSE/TSE mad cow disease. the other firewall they were speaking of protecting these children would have been the feed ban, which we now know was nothing more than ink on paper. 3 suspect CJD cases as we speak in females under 30 in the USA, other young victims in the USA with CJD. who's going to follow the children from this nationwide long term case study of children to the TSE agent via the most high risk animals i.e. dead stock downer cattle i.e.. non-ambulatory ???

Since 1996, strong evidence has accumulated for a causal relationship between ongoing outbreaks, primarily in Europe, of a disease in cattle called bovine spongiform encephalopathy (BSE, or “mad cow disease”) and a disease in humans called variant Creutzfeldt-Jakob disease (vCJD). Both disorders, which are caused by an unconventional transmissible agent, are invariably fatal brain diseases with incubation periods typically measured in years (1). Transmission of the BSE agent to humans, leading to vCJD, is believed to occur via ingestion of cattle products contaminated with the BSE agent; the specific foods associated with this transmission are unknown. However, a recently published case-control study involving 132 vCJD cases in the United Kingdom (UK) showed evidence of an increased risk for vCJD associated with the frequency of consuming beef products likely to contain mechanically recovered meat and head meat (such as burgers, meat pies, and sausages) (2). Bioassays and molecular tests have enabled identification of what World Health Organization consultants have classified as “high-infectivity” and “lower infectivity” tissues of cattle with BSE (3). The high-infectivity tissues include the brain, spinal cord, retina, optic nerve, and dorsal root and trigeminal ganglia, suggesting that these tissues can pose a relatively high risk of transmission. The lower infectivity tissues include peripheral nerves (e.g., sciatic and facial nerves), tonsils, nictitating membrane (third eye lid), distal ileum, bone marrow, and possibly thigh muscle. The latter tissue from one cow with BSE transmitted disease to highly BSE-sensitive transgenic mice at a rate indicative of trace levels of infectivity.

About Me

My mother was murdered by what I call corporate and political homicide i.e. FOR PROFIT! she died from a rare phenotype of CJD i.e. the Heidenhain Variant of Creutzfeldt Jakob Disease i.e. sporadic, simply meaning from unknown route and source. I have simply been trying to validate her death DOD 12/14/97 with the truth. There is a route, and there is a source. There are many here in the USA. WE must make CJD and all human TSE, of all age groups 'reportable' Nationally and Internationally, with a written CJD questionnaire asking real questions pertaining to route and source of this agent. Friendly fire has the potential to play a huge role in the continued transmission of this agent via the medical, dental, and surgical arena. We must not flounder any longer. ...TSS